Survey of cosmetic products with probiotic or prebiotic claimsThe Danish Environmental Protection Agency/ Survey of cosmetic products with "probiotic" or "prebiotic" claims 3 Contents

Survey of cosmetic products with "probiotic" or

"prebiotic" claims

Survey of chemical substances in consum-er products No. 171 November 2018

2 The Danish Environmental Protection Agency/ Survey of cosmetic products with "probiotic" or "prebiotic" claims

Publisher: The Danish Environmental Protection Agency

Editors:

Marlies Warming,

Carsten Lassen,

Frans Christensen

(COWI A/S)

ISBN: 978-87-7038-003-4

Miljøstyrelsen offentliggør rapporter og indlæg vedrørende forsknings- og udviklingsprojekter inden for miljøsektoren,

som er finansieret af Miljøstyrelsen. Det skal bemærkes, at en sådan offentliggørelse ikke nødvendigvis betyder, at det

pågældende indlæg giver udtryk for Miljøstyrelsens synspunkter. Offentliggørelsen betyder imidlertid, at Miljøstyrelsen

finder, at indholdet udgør et væsentligt indlæg i debatten omkring den danske miljøpolitik.

Må citeres med kildeangivelse.

The Danish Environmental Protection Agency/ Survey of cosmetic products with "probiotic" or "prebiotic" claims 3

Contents

Summary 4

Sammenfatning 7

1. Background and objective 10

1.1 Background 10

1.2 Objective 10

1.3 Delimitation 10

2. Collection of knowledge about ingredients, product types and the

market for cosmetics with pro- and prebiotic claims 11

2.1 Methods 11

2.2 Results from knowledge collection 12

2.2.1 Probiotic ingredients 12

2.2.2 Prebiotic ingredients 13

2.2.3 Raw materials for pro- or prebiotic cosmetics 15

2.2.4 Relevant product types 15

2.2.5 Preservatives in pro- or prebiotic cosmetics 15

2.2.6 Market information on pro- and prebiotic cosmetics 16

3. Market investigation 17

3.1 Method 17

3.1.1 Extract from the database Kemiluppen 17

3.1.2 Retailer survey 17

3.2 Results from market research 18

3.2.1 Extract from the database Kemiluppen 18

3.2.2 Retailer survey 22

4. Claims of pro-/prebiotic cosmetics 28

4.1 Generally about claims of cosmetic products 28

4.2 Claims of pro- and prebiotic cosmetic products 29

5. Conclusion 34

References 37


Summary

The Danish Environmental Protection Agency is experiencing an increasing interest in cosmet-

ic products marketed with the claims "probiotic" and/or "prebiotic".

Objective

The Danish Environmental Protection Agency initiated this consumer project with the aim of

providing an overview and obtaining more knowledge about pro- and prebiotic products on the

Danish market. The following questions were investigated:

What are pro- and prebiotic ingredients and which are used in cosmetic products?

Which cosmetic product types are found in pro-/prebiotic versions?

What is the market share of cosmetic products with pro-/prebiotic claims?

Is there a price difference between pro-/prebiotic products compared to other cosmetic

products?

Is there a difference in durability (shelf life) between pro-/prebiotic products compared to

other cosmetic products?

Are cosmetic products with pro-/prebiotic claims certified with ecolabels?

What is the range of pro-/prebiotic raw materials for cosmetics producers?

How and why are certain cosmetic products claimed as being pro- and/or prebiotic? Are

the pro-/prebiotic cosmetic products marketed with special health-related claims?

Method

The questions above were investigated through information gathered from stakeholders, litera-

ture searches, and a market survey.

Two Danish industry associations, several Danish and foreign cosmetics manufacturers, the

largest Danish cosmetics retailers (Danish Supermarket, COOP, Matas, Magasin, Pharma-

cies) and other experts in the field were contacted to collect information to answer the above

questions.

As part of the market survey, the Chemistry section of the Danish Consumer Council Think

provided an extract of their product database, which contains information about a large propor-

tion of cosmetic products that are on the market in Denmark. The extract was made by search-

ing for the names of probiotic bacteria in the ingredient lists. In addition, a retailer survey was

carried out to identify cosmetics products with pro-/prebiotic claims from both internet retailers

and in a department store.

Results and conclusions

Generally, there is limited available knowledge about ingredients, products and/or an overview

of the pro-/prebiotic cosmetics market in Denmark.

Pro- and prebiotic ingredients are well known as dietary supplements and, as a rule, the defini-

tions of the concepts have been developed based on their use as dietary supplements.

The common definition of "probiotic" involves living microorganisms having a beneficial effect

on the host, whereby the effect can be documented. Living microorganisms, however, are

used only to a limited extent in cosmetic products. Nonetheless, within the cosmetics sector, a


number of ingredients that are merely produced by microorganisms are referred to as "probi-

otic". The most widely used bacterial strain is Lactobacillus. Bifidobacterium is also often used

for production of cosmetics ingredients, whereas ingredients derived from Lactococcus, Strep-

tococcus, Leuconostoc, Pediococcus and Saccharomyces are listed less frequently on the

ingredient lists of certain products.

The common definition of "prebiotic" substances implies that the substances can cause specif-

ic changes in the composition and/or in the activity of the host's microflora, that the substances

cannot be degraded by the host's own enzymes, that they have a beneficial effect on the

health of the host and that the effect can be documented. In cosmetics, the term “prebiotic

ingredients” is used in a broader context, i.e. as substances that can be exploited by beneficial

bacteria or as substances produced by microorganisms (as mentioned above, these are also

often referred to as probiotic ingredients in relation to cosmetics). Alpha-Glucan Oligosaccha-

ride, inulin, lactic acid, and lactobacillus ferment are the ingredients most commonly found in

products that claim to be pro-/prebiotic in the retailer survey.

Both communication with the stakeholder (including stakeholder associations, cosmetics man-

ufacturers and retailers) and an internet search show that pro- and prebiotic products are

mostly leave-on products, but also include a few rinse-off products. The products identified

from the internet retailers' websites are mainly for facial care (69%). In addition, there are a

few products for body care (11%), soap and hygiene (11%), and some products for baby care

products, hair care and make-up (3% in each category).

According to stakeholder consultation, cosmetic products with pro-/prebiotic claims are still

niche products; the market share of these products is below 1% (in turnover). In the examina-

tion of the products in a department store (which primarily led specialty and luxury cosmetics,

as the relevant products are essentially only found among such products) the number of pro-

/prebiotic products accounted for 1.7% of all facial care products. The extract from the product

database showed 0.59% of products that contained a bacterially-derived ingredient. The dif-

ferent estimates were on the same order of magnitude and confirm that pro-/prebiotic products

constitute a niche segment in cosmetics. At the time of writing, the products were not yet found

in discount- and supermarkets, but only in department stores, specialized cosmetics retailers,

or pharmacies. A significantly larger selection was available through internet retailers. The

data support the stakeholder estimate of a total market share of below 1% for cosmetic prod-

ucts with pro-/prebiotic claims.

A total of 932 products were investigated in the retailer survey, of which 80 unique products

were marketed with pro-/prebiotic claims.

Products with pro-/prebiotic claims were similarly priced as other specialty cosmetic products.

With regard to durability dates, the results showed that pro-/prebiotic products did not differ

from other cosmetic products. About one third of the pro-/prebiotic products were labelled with

the ECOcert label. In addition, a few of the products in the department store were labelled with

the Nordic Ecolabelling Swan.

The claims of the pro- and prebiotic products identified in the retailer survey were reviewed.

The claims "probiotic", "prebiotic" or similar are typically used in: i) the product description

printed on the packaging; ii) a display on the Internet retailers’ product homepages; or iii) part

of the product/brand name that is printed on the packaging. Most claims relate to some gen-

eral positive health effects on the skin; for example, “creating better balance" or "moisturizing".

In addition, some of the pro-/prebiotic products claim to be effective against skin disorders

and/or skin problems. However, these claims are also common for other cosmetic products. In

contrast, health-related claims concerning changes in the skin's naturally occurring microbial

community appear to be used specifically for pro-/prebiotic cosmetics.


Overall, a comparison of information obtained from stakeholder consultation, literature/internet

searches, the product database and the retailer survey indicates that there is no clear relation-

ship between pro-/prebiotic claims and ingredients in cosmetics.


Sammenfatning

Miljøstyrelsen oplever en stigende interesse for kosmetiske produkter markedsført med an-

prisningen ”probiotisk” og/eller "præbiotisk".

Formål

Miljøstyrelsen har igangsat dette forbrugerprojekt med det formål at danne et overblik og frem-

skaffe mere viden om pro- og præbiotiske produkter på det danske marked. I den forbindelse

undersøges følgende spørgsmål:

Hvad er pro- og præbiotiske ingredienser og hvilke bruges i kosmetiske produkter?

Hvilke kosmetiske produkttyper findes i probiotiske/præbiotiske udgaver?

Hvor stor en markedsandel har pro- og præbiotisk anpriste kosmetiske produkter?

Er der prismæssig forskel på probiotiske/præbiotiske produkter ift. "konventionelle"

produkter?

Er der forskel i holdbarheden mellem probiotiske/præbiotiske produkter ift. "konven-

tionelle" produkter?

Er probiotiske produkter certificeret i forhold til nogle af de klassiske mærkningsord-

ninger?

Hvor stort er udvalget af probiotiske/præbiotiske råvarer for producenterne?

Hvordan og af hvilken årsag anprises kosmetiske produkter som pro- og/eller præbio-

tiske? Markedsføres de probiotiske/præbiotiske kosmetiske produkter med særlige

sundhedsrelaterede anprisninger?

Metode

De nævnte spørgsmål undersøges dels gennem informationsindhentning fra brancheaktører

og litteratursøgning, dels gennem en markedsundersøgelse.

To danske brancheorganisationer, en række danske og udenlandske kosmetikproducenter og

større kosmetikforhandlere (Dansk Supermarkedet, COOP, Matas, Magasin, Apotekerne)

samt andre videnspersoner er blevet kontaktet for at indsamle informationer til ovenstående

spørgsmål.

I markedsundersøgelsen er der foretaget et udtræk af Forbrugerrådet Tænk Kemis database,

som indeholder en stor andel af kosmetiske produkter, som er på markedet i Danmark. Ud-

trækket blev foretaget ved at søge på navne af probiotiske bakterier i ingredienslisterne. Der-

udover blev der gennemført en butiksundersøgelse som identificerede en række pro-

/præbiotisk anpriste produkter både på internetforhandlernes hjemmesider og i en fysisk butik.

Resultater og konklusioner

Generelt er der begrænset tilgængelig viden om ingredienser, produkter og/eller overblik over

markedet af pro-/præbiotisk kosmetik i Danmark.

Pro- og præbiotiske ingredienser er velkendt som kosttilskud og definitioner af begreberne er

som udgangspunkt udviklet på baggrund af deres anvendelse inden for fødevarer/kosttilskud.

Den gængse definition af "probiotisk" indebærer anvendelsen af levende mikroorganismer,

som har en gavnlig effekt på værten, samt at effekten kan dokumenteres. Levende mikroorga-

nismer anvendes dog kun i yderst begrænset omfang i kosmetiske produkter. Inden for kos-


metik derimod betegnes en række ingredienser, som er produceret vha. mikroorganismer,

som "probiotiske". Den mest anvendte bakterieslægt er Lactobacillus. Bifidobacterium fore-

kommer også ofte, mens ingredienser afledt af Lactococcus, Streptococcus, Leuconostoc,

Pediococcus og Saccharomyces også er listet på ingredienslisterne af enkelte produkter.

Den gængse definition på "præbiotiske" stoffer indebærer, at stofferne giver specifikke æn-

dringer i sammensætningen og/eller i aktiviteten af værtens mikroflora, at stofferne ikke kan

nedbrydes af værtens egne enzymer, at de medfører en gavnlig effekt på værtens sundhed og

at effekten kan dokumenteres. Indenfor kosmetik omtales præbiotiske ingredienser noget

bredere, dvs. som stoffer, der kan udnyttes af gavnlige bakterier eller som stoffer, der er pro-

duceret vha. mikroorganismer (som nævnt ovenfor betegnes disse også ofte som probiotiske

ingredienser i forhold til kosmetik). Alpha-Glucan Oligosaccharide, Inulin, Lactic Acid, og Lac-

tobacillus Ferment er de ingredienser, som er hyppigst fundet i pro-/præbiotisk anpriste kos-

metiske produkter i butiksundersøgelsen.

Både kommunikation med branchen (bl.a. brancheorganisationer, kosmetikproducenter og -

forhandlere) og søgning af pro- og præbiotisk anpriste produkter i webshops viser, at de anpri-

ste produkter primært er leave-on produkter, men også omfatter få rinse-off produkter. Produk-

terne, som er identificeret fra internetforhandlernes hjemmesider, er hovedsageligt til ansigts-

pleje (69%). Derudover blev der fundet få produkter til kropspleje (11%), sæbe og hygiejne

(11%), og enkelte produkter inden for babypleje, hårpleje og kosmetik/make-up (3 % i hver

kategori).

Mht. markedsandelene vurderer flere branchekontakter at pro- og præbiotisk anpriste produk-

ter stadig er nicheprodukter og at markedsandelen af disse produkter ligger under 1% i om-

sætning. I undersøgelsen af produkterne i en fysisk butik (som fører primært special- og luksu-

riøskosmetik, da de relevante produkter udelukkende markedsføres dér) udgjorde antallet af

de pro-/præbiotisk anpriste produkter 1,7% af alle produkter inden for ansigtspleje, mens ud-

trækket fra Kemiluppens database viste 0,59% produkter, som indeholdt en bakterieafledt

ingrediens. De forskellige estimater ligger i samme størrelsesorden og bekræfter, at pro- og

præbiotisk anpriste produkter udgør et nichesegment indenfor kosmetik. Produkterne findes

(endnu) ikke i dagligvarebutikker (discountmarkeder og supermarkeder), men derimod i stor-

magasiner, hos specialiserede kosmetikforhandlere, eller på apoteker. Et væsentlig større

udvalg er tilgængelig via internetforhandlerne. Alt i alt bekræfter ovenstående branchens for-

modning om at den samlede markedsandel ligger under 1%.

I alt indgik 932 produkter i butiksundersøgelsen, heraf blev 80 unikke produkter anprist med

pro- og/eller præbiotisk.

Prismæssigt ligger pro- og præbiotisk anpriste produkter på niveau med andre specielt udvik-

lede kosmetiske produkter. Mht. til konservering og holdbarhed viser resultaterne, at pro- og

præbiotisk anpriste produkter ikke afviger fra anden kosmetik. Ca. en tredjedel af de pro-

/præbiotisk anpriste produkter var mærkede med ECOcert mærket. Enkelte produkter, som

forhandledes i stormagasinet, var derudover mærket med det nordiske miljømærke Svanen.

Anprisningerne af de i butiksundersøgelsen identificerede pro- og præbiotisk anpriste produk-

ter blev gennemgået. Anprisningen som "probiotisk", "præbiotisk" eller lign. fremgår typisk af: i)

produktbeskrivelsen, som er printet på emballagen, ii) vises på forhandlerens produkthjemme-

side, eller iii) er en del af produkt-/mærkenavnet, som vises på forsiden af emballagen.

De fleste anprisninger relaterer sig til nogle generelle positive sundhedseffekter i huden, f.eks.

skabe "bedre balance" eller virke "fugtgivende". Derudover anprises nogle af de pro-

/præbiotiske produkter til at kunne afhjælpe hudlidelser og/eller hudproblemer. Disse anpris-

ninger er også almindelige for andre kosmetiske produkter. Det, der tilsyneladende adskiller

anprisningen af pro-/præbiotisk kosmetik fra anden kosmetik, er, når der fremhæves effekter,


som vedrører ændring af hudens naturligt forekommende bakteriesamfund. Sammenligning af

resultater fra branchen, litteraturen/internettet, produktdatabasen og butiksundersøgelsen

viser, at der ikke er en entydig sammenhæng mellem anprisninger og ingredienser i kosmetik.


1. Background and objective

1.1 Background The Danish Environmental Protection Agency is experiencing an increasing interest in cosmet-

ic products marketed with the claim "probiotic" and/or "prebiotic".

Probiotic food products such as fermented milk products and food supplements (probiotics)

are used for their beneficial effects on health, e.g. by counteracting diarrhoea (Medical Manu-

al, 2016). Prebiotics are short- or long-chain carbohydrates and known from their use as die-

tary supplements. Prebiotics have beneficial effects on the intestinal microbiota and therefore

on the health of the host (Vignæs, 2012). The concepts "probiotic" and "prebiotic" are dis-

cussed in more detail in Chapter 2.

The positive effects of pro- and prebiotics on the intestinal bacterial community may also be

applicable to the skin's bacterial community (Forum, 2018; Welt, 2016).

However, it is not clear how effective pro- or prebiotic cosmetic products are, if their effects are

consistent with the product's claims, how the products are advertised and how consumers can

recognize a pro- or prebiotic cosmetic product. The Danish Environmental Protection Agency

initiated this study to illuminate some of these aspects.

1.2 Objective The purpose of this study was to provide an overview and more knowledge about products

that claim to be pro- and prebiotic on the Danish market, including:

What are pro- and prebiotic ingredients and which are used in cosmetic products?

Which cosmetic product types are found in pro-/prebiotic versions?

What is the market share of cosmetic products with pro-/prebiotic claims?

Is there a price difference between pro-/prebiotic products compared to other cosmetic

products?

Is there a difference in durability between pro-/prebiotic products compared to other cosmet-

ic products?

Are cosmetic products with pro-/prebiotic claims certified with ecolabels?

What is the range of pro-/prebiotic raw materials for cosmetics producers?

How and why are certain cosmetic products claimed as being pro- and/or prebiotic? Are the

pro-/prebiotic cosmetic products marketed with special health-related claims?

1.3 Delimitation This project was primarily a survey with the above objectives. Thus, the project was not a

study of the effects of pro- and/or prebiotically advertised cosmetic products on skin or other

organs.

Therefore, the survey does not include an assessment of documentation for any health effects

that might form a basis for the claims.

There are also a number of probiotic products that claim beneficial skin effects on the market,

intended as dietary supplements. These products were not included in this survey, which fo-

cused only on cosmetics applied to the skin.


2. Collection of knowledge about ingredients, product types and the market for cosmetics with pro- and prebiotic claims

The primary purpose of this chapter is to provide an overview of available knowledge from the

cosmetics stakeholders, supplemented with information retrieved via literature search.

2.1 Methods Information was collected by internet search and via communication with stakeholders.

The following stakeholder organizations, companies and other experts in the field were con-

tacted:

Stakeholder organizations:

Cosmetics & Hygiene industry association (formerly SPT)

Industry association VKH - Washing, cosmetics and household industry

Cosmetics Manufacturers:

DermaP harm A/S, Denmark

Allison A/S, Denmark

Aurelia Skincare Ltd, United Kingdom

Esse Skincare, South Africa

Chrisal NV, Belgium

Possible source suppliers of pre- and probiotics:

Chr Hansen Holding A/S

Cosmetics retailers:

Danish Supermarket Group (Netto discount market, Føtex supermarket, Bilka su-

permarket, Salling department store)

COOP (Kvickly supermarket, Super Brugsen supermarket, Dagli 'Brugsen super-

market, Irma supermarket, Fakta discount market)

Magasine department store

Matas cosmetics retailer

Danish Pharmacies Association

Others:

Danish Consumer Council Think Chemicals (Danish consumer organisation)

Danish Beauty Award (DBA)

Helle Forum, cosmetics journalist and author

The above organisations were asked the questions listed in section 1.2 by the respondents’

preferred communication form (telephone, e-mail or interview). Answers were anonymous and

companies/organizations are generally referenced as "stakeholders" in this report.


2.2 Results from knowledge collection Communication with the stakeholders made it clear that the pro-/prebiotic cosmetics are

"trendy" and are the subject of great interest among most players. The trend is reflected in the

fact that several stakeholders hype pro-/prebiotic cosmetics as a growing market and that

these products have won prizes at the Danish Beauty Awards in 2017 and 2018 (Danish

Beauty Awards 2017, 2018). The subject has also been a discussion topic at the annual Euro-

pean In-Cosmetics Conference in Amsterdam.1

Generally, however, there is limited knowledge available about ingredients, products and the

market for pro-/prebiotic cosmetics in Denmark.

In the following section ingredients that are typically considered as being probiotic and/or

prebiotic, as well as the basis for pro- or prebiotic claims on the products, are examined.

2.2.1 Probiotic ingredients

The general definition of probiotics is "live microorganisms which when administered in ade-

quate amounts confer a health benefit on the host" (Hills et al. 2014). Probiotic products like

sour milk products or dietary supplements (probiotics) are used for their beneficial effects on

health, e.g. by counteracting diarrhoea (Medical Manual, 2016). The international expert panel

on probiotics clarifies that products containing ingredients produced by microorganisms or

containing dead microorganisms are not covered by the definition of probiotics (Hills et al.,

2014).

According to an article in Dermatology Times (Farris, 2016), which is an online newspaper for

a global medical network, probiotic bacteria have proven skin benefits that are related to their

properties as fermentation bacteria. The article describes that during fermentation, acidic

compounds such as lactic acid are produced. These compounds reduce the pH of the skin and

thus counteract the growth of pathogenic bacteria. At the same time, the growth of "beneficial

bacteria" is favoured. Some probiotic bacterial strains also produce antimicrobials, organic

acids and hydrogen peroxide, which may inhibit pathogens (Farris, 2016).

According to communications with some of the stakeholders, the definitions of pro- and prebi-

otics in cosmetics is not as defined as it is in food. So far, living bacteria are only used to a

limited extent in cosmetic products because their viability, purity and effect are difficult to con-

trol in cosmetic products (Dobos, 2017; personal communication with stakeholders, 2018).

A recently published article on probiotic cosmetic products in the Danish magazine "Kosmetik"

(Forum, 2018) mentions that there are currently only two products containing live probiotic

bacteria in the Danish market. According to the article, the term "probiotic" is used more

broadly in cosmetics and includes ingredients that are not living but which have been obtained

by means of probiotic bacteria such as lactic acid bacteria, also called Lactobacillus (Forum,

2018). The article divides "probiotic ingredients" in cosmetics into four "levels" or groups (Fo-

rum, 2018):

1. Fermentation products or concentrates from fermentation. Probiotic bacteria are grown

on a substrate and afterwards filtered out from the solution, but the solution still contains

metabolites2 from the bacteria. These metabolites may include antioxidants, amino acids

or vitamins.

2. Cell lysates – The broth of probiotic bacteria is not filtered, but the bacteria are destroyed

so that cell contents and parts of cell walls are in solution.

1 As an examples, the program of the conference contained presentations on "New claims in skincare:

anti-pollution and probiotic ingredients" or " Keep your skin flora happy".

2 Metabolites are intermediate substances that arise during biochemical transformation of substances in

cells of living organisms (metabolism), e.g. in the metabolism of the bacteria.

http://www.in-cosmetics.com/en/Sessions/52255/New-claims-in-skincare-anti-pollution-and-probiotic-ingredients

http://www.in-cosmetics.com/en/Sessions/52255/New-claims-in-skincare-anti-pollution-and-probiotic-ingredients

http://www.in-cosmetics.com/en/Sessions/52839/Keep-your-skin-flora-happy


3. Tyndallization – The probiotic bacteria are killed before use in the formulation. Thus,

bacteria cannot propagate on the skin, but they can still bind to the skin's receptors and

thus block access to pathogenic bacteria. This mechanism of action is called competitive

inhibition.

4. Living probiotic bacteria - Live bacteria are added to the cosmetic product with the pur-

pose of colonizing the skin when the product is used.

According to stakeholder consultation, lactic acid bacteria, Lactobacillus, is the most used

bacterial strain in the manufacture of cosmetics, followed by Bifidobacterium. A search for

"Lactobacillus" in the CosIng database3 shows that there are over 350 ingredients related to

the Lactobacillus genus. The ingredients related to Lactobacillus can be divided into four

groups (INCI names are given in brackets):

Lactobacillus bacteria (LACTOBACILLUS)

Lactobacillus fermentation product (LACTOBACILLUS FERMENT)

Lactobacillus fermentation product filtrate (LACTOBACILLUS FERMENT FILTRATE)

Lactobacillus bacterial lysate (LACTOBACILLUS LYSATE)

The CosIng database lists a large number of different fermentation products whose names

differ according to the substrate and the microorganisms that have been used for the produc-

tion of the ingredient. The substrates usually consist of different plant species and parts. Apart

from Lactobacillus, the following microorganisms often occur in the ingredient names: Aceto-

bacter, Aspergillus, Bacillus, Bifidobacterium, Lactococcus, Leuconostoc, Pediococcus, Sac-

charomyces, Streptococcus and Zygosaccharomyces.

Many of these ingredients are labelled as skin conditioners or humectants in the CosIng data-

base.

According to the stakeholder consultation, most products with probiotic claims contain "Lacto-

bacillus ferment". In addition to Lactobacillus, the following microorganisms have been identi-

fied during the stakeholder consultation as well as an internet search on ingredient lists in

cosmetic products on the Danish market:

Bacillus

Bifidobacterium

Lactococcus

Streptococcus

Micrococcus.

It was noted that the metabolites (e.g. antioxidants, amino acids or vitamins) in fermentation

products (first group of "probiotic” ingredients) are common ingredients in a variety of cosmetic

products. In most cases, these ingredients do not lead to probiotic claims about the cosmetic

products.

2.2.2 Prebiotic ingredients

Prebiotics are also known from their use as nutritional supplements in foods. Prebiotics act by

inducing specific changes in the composition and/or in the activity of the intestinal microbiota,

and thus have a beneficial effect on the health of the host.

Prebiotics in dietary supplements are short or long chain (possibly branched) carbohydrates

made up of different types of monomers. The monomers are linked with bonds that cannot be

3 CosIng is the EU Commission's database on information on cosmetic ingredients.

https://ec.europa.eu/growth/sectors/cosmetics/cosing_en

https://ec.europa.eu/growth/sectors/cosmetics/cosing_en


degraded by human digestive enzymes, but are rather metabolized and utilized by specific

bacteria (Vignæs, 2012).

Specific requirements are imposed on a substance, if it is to be defined as a prebiotic dietary

supplement. The following substances, which are used as dietary supplements and meet the

requirements for non-digestion in the intestine, are recognized as prebiotics (Vignæs, 2012):

fructans, which may be fructoligosaccharides or inulin

galacto-oligosaccharides, consisting of galactose monomers

lactulose, which is a disaccharide consisting of galactose and fructose.

An international research association has recently proposed to extend the definition of prebiot-

ics in order to include more than strictly intestinal and dietary uses, as well as more substanc-

es in addition to the above-mentioned carbohydrates:

conjugated linoleic acid

polyunsaturated fatty acids

polyphenols and phytochemicals.

Substances or substrates that are applied directly to the skin to give a positive health effect

are thus also included in the proposed definition. The selective use of the substrate by certain

microorganisms must be the cause of the health effects and the substrate must not be de-

graded by the host's own enzymes. According to this definition, the positive health effects

should be documented through scientific studies (with animals or humans) before a substance

or substrate can be recognized as prebiotic (Gibson et al., 2017).

In current applications in cosmetic products, the understanding of term “prebiotic” is less de-

fined. A cosmetics manufacturer of prebiotic cosmetics products defines prebiotics on its web-

site as follows: "Prebiotics are a food source for beneficial microbes to give them a competitive

advantage. By giving them food, they proliferate and thrive, thereby excluding pathogenic

(harmful) bacteria"4. According to the opinions of some of the contacted stakeholders, groups

1 – 3 of probiotic cosmetic ingredients as described in 2.2.1 should rather be referred to as

"prebiotic" than "probiotic". Still, the ingredients from group 1 – 3 are also broader than the

definition of prebiotics above (carbohydrates, conjugated linoleic acid, polyunsaturated fatty

acids, polyphenols and phytochemicals).

As prebiotics in cosmetics, probiotic cell lysates or probioactives are often mentioned. These

are degraded probiotic bacteria containing prebiotic substances (Dobos, 2017, stakeholder

communications). The article in DermatologyTimes discusses the following ingredients as

prebiotics in cosmetics: Cell lysates of probiotic bacteria containing hyaluronic acid, sphingo-

myelinase (an enzyme), lipotechoinsyre (part of the cell wall of certain bacteria), peptidoglycan

(part of the cell wall), lactic acid, acetic acid and diacetyl (Farris, 2016). In addition, some of

the cosmetics manufacturers contacted mention the following ingredients: lactose, lactis pro-

teinum (milk protein) and inulin.

For most of the mentioned ingredients INCI names (in capital letters) are available:

fructooligosaccharides

galactooligosaccharides

ALPHA-GLUCAN OLIGOSACCHARIDE

lactulose

HYALURONIC ACID

Sodium Hyaluronate

LACTIC ACID

4 Anonymous.


ACETIC ACID

diacetyl

LACTOSE

LACTIS PROTEINUM

MILK PROTEIN

INULIN

Several of these ingredients are commonly found in cosmetic products (e.g. lactic acid and

hyaluronic acid), and their presence can therefore not directly be linked to pro- or prebiotic

claims of products. However, the stakeholder consultation and literature search also revealed

that a few manufacturers claim their products as pro-/prebiotic solely based on these ingredi-

ents.

2.2.3 Raw materials for pro- or prebiotic cosmetics

According to stakeholder information, many cosmetics manufacturers have their own laborato-

ries for the production of pro- or prebiotic ingredients. In addition, there are (bio-)chemical

companies that develop pro- or prebiotic ingredients and supply the cosmetics manufacturers.

For example, the chemical company BASF uses Lactobacillus in the manufacture of skin care

and dental care products, as well as deodorants (Cosmetics Design Europe, 2017). According

to the information the authors have been able to obtain in this project, there are currently no

Danish suppliers of pro-/prebiotic ingredients for cosmetics. Some cosmetics manufacturers

indicate that the range of raw materials is still quite limited but growing.

2.2.4 Relevant product types

The internet search and communication with stakeholders show that pro- and prebiotic claims

are mainly used for facial skin products. These mainly include leave-on products (products that

are applied to the skin and remain there), as well as a few rinse-off products (products washed

off after application, such as facial scrubs, shampoo and hand soap).

Pro- and prebiotic products typically focus on certain "skin problems" such as redness, skin

irritation or skin diseases such as acne. Claims are also made that the products prevent aging

and inflammation or are particularly suitable for sensitive skin. According to stakeholder com-

munication, the positive effects of pro-/prebiotic ingredients are documented in the scientific

literature.

It is noted that there are many other products that are also claimed to remedy the aforemen-

tioned "skin problems", but which are not marketed as pro- or prebiotic cosmetic products.

2.2.5 Preservatives in pro- or prebiotic cosmetics

If a cosmetic product intentionally contains living bacteria, the opportunities for adding pre-

servatives are limited, since the preservatives may kill the desired bacteria. However, since

the vast majority of cosmetic products with pro-/prebiotic claims do not contain living bacteria,

there is generally no difference in the addition of preservatives between pro- or prebiotic cos-

metics and cosmetics. Chapter 3 compares the durability between pro-/prebiotic cosmetics

and other cosmetics in order to detect differences in shelf life duration.

According to stakeholder information, the presence of living bacteria in a cosmetic product

requires a highly selective preservation system. Otherwise, no information was obtained on

specific preservatives and/or selective preservative systems in pro- or prebiotic cosmetics.

A few cosmetic products from a single manufacturer which are available on the Danish market

via internet retailers and which contain living bacteria contain no substances identified as pre-

servatives. Information on the shelf life or recommended storage temperature for these prod-

ucts was not available.


When using products containing living microorganisms, the consumer should be aware that

the product should not be combined with another (conventional) product that contains pre-

servatives, as the preservatives may have an inhibitory effect on the living probiotic bacteria

(Forum, 2018a, personal communication).

2.2.6 Market information on pro- and prebiotic cosmetics

Pro- and prebiotic cosmetic products are available through cosmetics retailers (in physical

stores and/or via online shops) or directly from cosmetics manufacturers online. Some manu-

facturers market entire skin care series as pre-/probiotic while others just market specific

products, e.g. skin types, as pro- and/or prebiotic.

Several stakeholders (personal communication) indicate that the pro- and prebiotic products

are priced at the same level as other special or luxurious cosmetic products. Furthermore, they

follow the same pricing rules as cosmetic products in general. Since many pro- and prebiotic

products are new and specially developed, they are often found on the high end of the scale of

prices. One manufacturer indicates that the price of the cosmetic product is also dependent on

the content/concentration of the pro- or prebiotic ingredients.

According to information from the stakeholders, pro-/prebiotic products are still niche products,

available only to a limited extent in physical stores. Therefore, they represent a small portion of

the total turnover of skin care products (<1%). A number of convenience stores (discounters

and supermarkets) state that they currently do not offer any cosmetic products with pro- or

prebiotic claims.

Pro- and prebiotic products may, however, be found in department stores, in specialized cos-

metics retailers, or in pharmacies. A larger selection is available through internet retailers.

Communication with the stakeholders and searches on retailers’ online shops also indicated

that more pro- or prebiotic products may be available from a store's online shop than from the

shelf in the physical store of the same retailer. Some of the pro- and prebiotic products are

marketed specifically to cosmetologists.

During stakeholder consultation and internet search, 16 brands5 of products with pro- or prebi-

otic claims available through Danish retailers have been identified. Only four of these brands

are available in physical stores (department stores or cosmetics retailers).

5 Retailer and brand names are not listed in this report, as requested by the Danish Environmental Protec-

tion Agency. However, the Danish EPA is familiar with the names.


3. Market investigation

The objective of the market study was to identify cosmetic products claimed to have pro- and

prebiotic qualities at retailers in order to: i) estimate the market share of cosmetic products

with pro- and prebiotic claims ii) assess whether these products differ in price or shelf life as

compared to conventional products, iii) investigate if the products are labelled with ecolabels

for environmentally friendly cosmetics, and; iv) survey which claims are used to promote the

products (see also Chapter 4).

3.1 Method

3.1.1 Extract from the database Kemiluppen

The Danish Consumer Council Think Chemicals launched the app "Kemiluppen" in December

2015, allowing consumers to scan the barcode of cosmetic products with their smartphone.

The product is subsequently assessed based on its constituents by the Consumer Council

Think, resulting in an overall assessment of the product's contained substances and recom-

mendations for consumers6.

In the database, it is possible to search for products by ingredients. The extraction of products

with certain ingredients compared to the number of all products from the database may be

used as an indication of the market share of certain cosmetic products.

However, the database does not contain information about claims of the products. Therefore,

data on products with pro-/prebiotic claims cannot be extracted. Instead, an extract has been

made of products containing ingredients that relate to the identified probiotic microorganisms:

• Lactobacillus

• Bacillus

• Bifid* (Bifido, Bifida, Bifidobacterium)

• Lactococcus

• Streptococcus

• Micrococcus.

Extracts have been made for products from the entire database, i.e. all product categories of

cosmetic products are included.

3.1.2 Retailer survey

In this report, the term 'retailer' covers both internet retailers and physical stores. In the retailer

survey, specific information on cosmetic products was collected:

Product category

Retailer

Date of registration

Volume (ml/g)

Price

Price per volume

Shelf life, before and after opening

Manufacturer (only for pro-/prebiotic products)

Place of production (only for pro-/prebiotic products)

6 http://kemi.taenk.dk/bliv-klogere/test-det-betyder-kolberne-b-og-c (in Danish).

http://kemi.taenk.dk/bliv-klogere/test-det-betyder-kolberne-b-og-c


Pro-/prebiotic ingredients (only for pro-/prebiotic products)

Pro-/prebiotic claim(s) (only for pro-/prebiotic products)

Ecolabel (Swan, EU Flower or EcoCERT; only for pro-/prebiotic products).

In order to compare results from the retailer survey with results from the Consumer Council

Think Chemicals database, the same product categories as used in the database are used in

the retailer survey. The database works with a category called "Cosmetics", which more spe-

cifically refers to make-up products. The category is therefore called "cosmetics/make-up"

here.

Survey of products from internet Retailers

In the collection of information (Chapter 2), eight retailers were identified either having an

online shop and physical stores (three retailers) or only sale via the internet (five retailers).

Subsequently, the eight internet retailers' websites were searched for more products with pre-

or probiotic claims. Searches on the internet retailers’ websites were conducted partly by

searching specifically for brands and products identified in Chapter 2 (Section 2.2.6), as well

as by searching for products with the following search terms:

probiotisk

probiotic

probiotika

præbiotisk

præbiotika

prebiotisk

prebiotic.

Survey of products from a physical store

A single physical store (a department store) was chosen as an example of a physical store. In

this shop, pictures were taken of all leave-on face care products from the following product

categories:

make-up remover/cleaning

creams and lotions

serums and oils

skin tonic, mist, toner

eye cream/eye serum.

These choices were made to concentrate the resources allocated to the project on the most

relevant product categories with a certain probability of detecting products with pro-/prebiotic

claims.

The products were photographed in May-June 2018.

3.2 Results from market research

3.2.1 Extract from the database Kemiluppen

At the time of the data collection (March 2018), the database contained 11,128 active products

registered with separate barcodes. Throughout the database, 66 barcodes were found that

included ingredients with the bacterially-derived names. This figure corresponds to 0.59% of

all barcodes.

Some products are registered several times under different barcodes. The corrected number

of products according to unique product names is 59. Six of the products contained more than

one bacterially-derived ingredient. The results are summarized in TABLE 1 below. The data

indicate that Lactobacillus, Micrococcus and Bifidobacterium are the most commonly used


bacteria for the formulation of cosmetic products. No products containing ingredients derived

from Streptococcus were identified.

TABLE 1. Results from the consumer product database by bacterial names. Note that some

products contain more than one bacterially-derived ingredient.

Active barcodes in total 11.128

Number of barcodes with bacteria name 66

% Number of barcodes with bacteria name out of all barcodes 0.59%

Number of products with bacteria name 60

Number of barcodes per bacteria name Lactobacillus 31

Bacillus 1

Bifid* (Bifido, Bifida, Bifidobacterium) 10

Lactococcus 2

Streptococcus 0

Micrococcus 22

From TABLE 2 it becomes clear that the majority of products containing bacterially-derived

ingredients is found in leave-on face care. Creams/lotions containing bacterially-derived ingre-

dients constitute 20 products (33%), the largest group of products containing bacterially-

derived ingredients. All face care products (49 products) make up 82% of the products with

bacterially-derived ingredients (TABLE 2). Leave-on face products account for 86% of all face

care products (provided that half of the products in the "Cleanser/ Makeup remover/ Wash"

category are leave-on, and the masks, scrubs and peelings are rinse-off).


TABLE 2. Number of products per category

Category Subcategory Number of

products

with bacteria-

derived in-

gredient

% products

out of the total

number of

products with

bacteria-

derived ingre-

dient

Number

of prod-

ucts in

total per

(sub-)

category

% products

with bacteria-

derived in-

gredient out

of all prod-

ucts from the

(sub-) cate-

gory

Face care In total 49 82% 1869 2.6%

Cleanser/ Makeup re-

mover/ Wash

10 16.7% 459 2.2%

Cream / lotion 20 33.3% 765 2.6%

Mask 1 1.7% 180 0.6%

Scrubs/ peeling 1 1.7% 106 0.9%

Serum 6 10.0% 89 6.7%

Skin tonic/ toner/ mist 6 10.0% 180 3.3%

Eye cream/ eye serum 5 8.3% 90 5.6%

Hair care In total 4 7% 1237 0.3%

Hair lacquer/ hair spray/

heat spray

1 1.7% 294 0.3%

Hair foams 1 1.7% 74 1.4%

Shampoo 2 3.3% 869 0.2%

Cosmetics/

make-up

In total 2 3% 243 0.8%

Mascara 1 1.7% 190 0.5%

Primer / fixer 1 1.7% 53 1.9%

Body care In total 5 8% 1179 0.4%

Body lotion/ body

cream

4 6.7% 806 0.5%

Hand care 1 1.7% 373 0.3%

In total 60 100.0% 4528 1.3%

In the following table (TABLE 3), the numbers of registrations of individual products by con-

sumers using the Kemiluppen app are summarized per category and expressed as number of

scans. How often a product has been scanned can be seen as an indication of consumer

interest in the product and provides information about the availability of the product. Half of the

registered products with bacterially-derived ingredients are face creams and lotions (48%). In

total, facial care products make up 90% of the scanned products, which again reflects the fact

that facial care products are the most important product type in cosmetics containing bacterial-

ly-derived ingredients.


TABLE 3. Number of scans per product category

Category Subcategory Number of

scans of prod-

ucts with bacte-

ria-derived in-

gredient

% scans out of the total num-

ber of scans of products with

bacteria-derived ingredient

Face care In total 22,514 90%

Cleanser/ Makeup remover/ Wash 3,359 13.4%

Cream/ lotion 12,035 48.0%

Mask 745 3.0%

Scrubs/ peeling 1,033 4.1%

Serum 2,076 8.3%

Skin tonic/ toner/ mist 1,535 6.1%

Eye cream/ eye serum 1,731 6.9%

Hair care In total 743 3.0%

Hair lacquer/ hair spray/ heat spray 13 0.1%

Hair foams 20 0.1%

Shampoo 710 2.8%

Cosmetics/

make-up

In total 989 3.9%

Mascara / vipper 881 3.5%

Primer / fixer 108 0.4%

Body care In total 801 3.2%

Body lotion/ body cream 645 2.6%

Hand care 156 0.6%

In total 25,047 100%

Registrations in the database are driven by consumer interest in the products, but do not nec-

essarily reflect that the products are also purchased correspondingly. In addition, it cannot be

assumed that consumers who use the app for obtaining chemical information about cosmetic

ingredients by scanning the products in stores are representative of cosmetic consumers in

general.

Twenty-one different brands of products with bacterially-derived names were identified (TA-

BLE 4). Most brands have only one product with a bacterially-derived ingredient (12 out of 21

brands), while only two brands have more than 10 products with bacterially-derived ingredi-

ents. Only two of the 16 brands identified in Chapter 2 are also found in the Consumer Council

Think's database (brand names not shown).

The poor consistency between the brands identified in Chapter 2 and the database is likely to

be explained by the following:

Products in the database are typically registered by consumers in the stores. The majority of

pro-/prebiotic products are not available in physical stores, but rather through internet retail-

ers or through cosmetologists.

In some cases, consumers register products which are not available through Danish retail-

ers (e.g. during travel abroad or self-imported products).

The content of bacterially-derived ingredients leads only in some cases to a pro-/prebiotic

claim. Claims about specific products identified from the database have been checked on

the retailers or manufacturers' websites. Nineteen of the 21 identified brands are not pro-


moted as being pro- or prebiotic. This shows that bacterially-derived ingredients are also

added for reasons other than marketing.

The database was established in 2015 and the data set used for this survey was from March

2018. Since products with pro-/prebiotic claims are relatively new, the likelihood that they

have already been recorded in the database is smaller than for products that have been on

the market for a longer time.

TABLE 4. Brands per number of products.

Brands per number of products with bacteria-derived ingredients Number of brands

Brands with 14 products 1


Brands with 8-12 products 0


Brands with 4-6 products 0



Brands with 1 product 12

3.2.2 Retailer survey

In the retailer survey, a total of 932 products (internet retailers + physical store) were investi-

gated, of which 80 unique products had pro- and/or prebiotic claims.

Product types identified from internet retailers' websites

A total of 70 different products with pro- and/or prebiotic claims (distributed across 25 different

brands) were identified from the eight selected internet retailers' websites.

The distribution of products by product type can be seen in Figure 1. Facial care products

account for approximately two-thirds of the largest group of products.

Figure 1. Distribution of products with pro-/prebiotic claims from internet retailers by product

type.

11%

3%

69%

3%

11% 3%

Body care

Cosmetics/ Make up

Facial skincare

Hair care

Soaps and hygiene

Baby care


TABLE 5 shows how the products are distributed across subcategories. Most products are

found in the subcategory of creams/ lotion and cleanser/ makeup remover.

TABLE 5. Number of products with pro-/prebiotic claims from internet retailers.

Category Subcategory Number Number with ecolabel

Face care 48 9

Cleanser / Makeup Remover / Wash 11 2

Creams and lotions 17 3

Serums and oils 8 0

Skin tonic / toner / mists 3 1

Eye cream / eye serum 5 2

Masks 4 1

Baby care 2 2

Baby lotion / baby cream 1 1

Baby oil 0 0

Baby salve 0 0

Baby shampoo 1 1

Cosmetics/Make-up 2 0

Blush / Highlighter 0 0

Concealer / Corrector 0 0

Lipstick/ Lipgloss / Lip liner 0 0

Primer / Fixer 1 0

Powder 1 0

Body care 8 5

Body lotion / body cream 5 3

Foot care 0 0

Hand care 1 1

Oils 1 1

Salve / gel 0 0

Sun care 0 0

Hair care 2 2

Balsam / conditioner / deep conditioner 1 1

Shampoo 1 1

Soap and hygiene 8 5

Deodorant 4 2

Intimate care 1 0

Handsoap, liquid 1 1

Body shampoo / body gel / foam bath / bath

salts

2 1

Product types identified in the department store

There was a total of 862 leave-on cosmetic products for facial care (distributed across 49

different brands) in the selected department store. Of these, 15 different products with pro-

and/or prebiotic claims were identified (distributed across five different brands). Only one of

the brands had not been identified in the survey of products from the internet retailers.


The following table (TABLE 6) shows how products with pro-/prebiotic claims are distributed

across subcategories within facial care. It is seen that most products belong to the subcatego-

ry “creams/lotions” and "serums and oils".

TABLE 6. Number of products with pro-/prebiotic claims in the department store.

Category Subcategory Number Number of

products with

pro-/prebiotic

claims

% Number of

products with

pro-/prebiotic

claims

Ansigtspleje 862 15 1.7%

Cleanser / Makeup Re-

mover / Wash

47 2 4.3%

Creams and lotions 446 4 0.9%

Serums and oils 205 8 3.9%

Skin tonic / toner / mist 45 0 0%

Eye cream / eye serum 115 1 0.9%

Pro- and prebiotic ingredients

The ingredient lists of the pro-/prebiotic products were reviewed for ingredients identified in

Chapter 2. Twenty-three unique ingredients were found (TABLE 7). Most of the pro-/prebiotic

products contain several of these ingredients. The most common ingredients, often found in

combination, are: Alpha-Glucan Oligosaccharide, Inulin, Lactic Acid, and Lactobacillus Fer-

ment/Lactobacillus. Most of the products with pro-/prebiotic claims (82%) contain at least one

ingredient in which the name of a microorganism occurs (e.g. Lactobacillus ferment or Saccha-

romyces lysate extract).


TABLE 7. Pro-/prebiotic ingredients in the products with pro-/prebiotic claims (INCI names

written in capital letters).


BIFIDA FERMENT LYSATE

Hansenula Ferment*

INULIN

Kloeckera Ferment*

LACTIC ACID

LACTIS PROTEINUM

LACTOBACILLUS

LACTOBACILLUS FERMENT

LACTOBACILLUS FERMENT LYSATE

LACTOBACILLUS/WATER HYACINTH FERMENT

LACTOCOCCUS FERMENT

LACTOCOCCUS FERMENT LYSATE

LACTOSE

LINOLEIC ACID

MILK PROTEIN

Pediococcus Ferment*

SACCHAROMYCES FERMENT

Saccharomyces lysate extract*

SODIUM HYALURONATE

SODIUM LACTATE

* Cannot be found in the same wording in the CosIng database.

Comparison of prices

In Figure 2, the average prices are broken down by product category for products with pro-

/prebiotic claims and 'conventional' products (in this context, understood as products without

pro-/prebiotic claims). Prices at internet retailers and physical stores are not considered to be

directly comparable; therefore, only products registered at the department store are included in

the comparison.

The prices are in the same range. It is noted that the average price of the products with pro-

/prebiotic claims is calculated from very few values, making a robust comparison impossible.

The figures confirm, however, the information received through communication with stake-

holders: significant differences in prices between pro-/prebiotic and conventional products are

not expected.


Figure 2. Average prices of pro-/prebiotic and conventional products.

Comparison of durability

If a cosmetic product has a shelf life of 30 months or less, the minimum durability date must be

stated on the packaging. The minimum durability date must be stated with either the hourglass

symbol or the text: "Should be used by the end of...". For products with a shelf life over 30

months, the period after opening must be indicated with the required jar symbol7.

None of the investigated products showed a shelf life of less than 30 months, but for most

products the shelf life after opening could be identified (TABLE 8). None of the products with

pro-/prebiotic claims differed remarkably from other products (e.g. with short shelf lives). The

comparison indicates that products with and without pro-/prebiotic claims do not differ in their

durability.

The internet retailers typically only show a picture of the front of the packaging on their prod-

ucts' websites. Products from internet retailers were not purchased for further study and infor-

mation for these products was therefore collected only from the websites. If durability sym-

bols/- dates were printed somewhere other than on the front of the product, the information

was not included on the websites.

TABLE 8. Comparison of durability of products per category identified in the department store.

Period after opening (months)

3 6 9 12 18 24

Number of products With pro-/prebiotic claims 1 1 9 3

'conventional' 3 173 34 284 59 95

7 https://mst.dk/kemi/kemikalier/regulering-og-regler/faktaark-om-kemikaliereglerne/maerkning-af-

kosmetik/ (in Danish)

0,0

5,0

10,0

15,0

20,0

25,0

30,0

35,0

40,0

Price (

DK

K/m

L)

Conventional products Products with pro-/prebiotic claims

https://mst.dk/kemi/kemikalier/regulering-og-regler/faktaark-om-kemikaliereglerne/maerkning-af-kosmetik/

https://mst.dk/kemi/kemikalier/regulering-og-regler/faktaark-om-kemikaliereglerne/maerkning-af-kosmetik/


Ecolabelling

Ecolabel criteria for environmentally- and/or health-friendly cosmetic products are available

from the Nordic Swan Standard8, the EU flower (only for rinse-off cosmetics)

9 and ECOcert

10

(private global certification company). None of these labelling schemes have criteria related to

the use of microorganisms or bacteria-derived ingredients in cosmetic products.

In the retailer survey, it was noted whether the products were labelled with one or more eco-

labels, i.e. the EU flower, the Nordic Swan or the ECOcert symbol. About one third of the

products with pro-/prebiotic claims was labelled (29 %, 23 of 80 unique products). All 23 la-

belled products were labelled with ECOcert and a few products, available in the department

store, were also labelled with the Nordic Swan.

It should be noted that the internet retailers typically only show a picture of the front of the

packaging on their websites. Products from internet retailers were not purchased for further

study and information for these products was, therefore, collected only from the websites. If an

ecolabel is printed on the back of the product, it was not available for this study (for the same

reason as described above for durability).

8 Swan critera document, 2018: http://www.nordic-ecolabel.org/product-

groups/group/?productGroupCode=090 (in Danish)

9 EU flower criteria document, 2014: https://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:32014D0893&from=EN

10 ECOcert standard criteria document, 2012: http://www.ecocert.com/sites/default/files/u3/Ecocert-

Standard/index.pdf

http://www.nordic-ecolabel.org/product-groups/group/?productGroupCode=090

http://www.nordic-ecolabel.org/product-groups/group/?productGroupCode=090

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014D0893&from=EN

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014D0893&from=EN

http://www.ecocert.com/sites/default/files/u3/Ecocert-Standard/index.pdf

http://www.ecocert.com/sites/default/files/u3/Ecocert-Standard/index.pdf


4. Claims of pro-/prebiotic cosmetics

This chapter describes the rules and requirements for claims made for cosmetic products in

accordance with the Cosmetics Regulation (section 4.1). In addition, the specific health-related

claims that are used in the marketing of the pro-/prebiotic cosmetic products identified in this

survey are described (section 4.2).

4.1 Generally about claims of cosmetic products In the Cosmetics Regulation

11 Chapter VI on Consumer Information, Article 20 provides rules

about claims for cosmetic products. Here, it appears that a cosmetic product available on the

market or in the context of advertising must not be subject to statements that imply product

characteristics or functions which the product does not have (Article 20, paragraph 1 of the

Cosmetics Regulation). This rule includes both labelling on the products' packaging and all

forms of marketing material, and applies to text, names, trademarks, pictures and symbols that

may mislead the consumer to believe that the product has properties that it does not. On the

basis of Article 20 (2) of the Cosmetics Regulation, the Cosmetics Claims Regulation12

has

adopted a list of common criteria for claims that may be applied to cosmetic products.

The Cosmetics Claims Regulation states that the so-called responsible person has to ensure

that the wording of the product's claim complies with the common criteria set out in Annex I of

the Cosmetics Claims Regulation. In addition, the responsible person must ensure that the

claims are substantiated by documentation in the dossier containing product information for

the cosmetic product referred to in Article 11 of the Cosmetics Regulation.

Annex I of the Cosmetics Claims Regulation sets out six common criteria for claims about

cosmetic products. The first criterion concerns legal compliance:

Claims that indicate that the product has been authorised or approved by a competent au-

thority within the Union shall not be allowed.

The acceptability of a claim shall be based on the perception of the average end user of a

cosmetic product, who is reasonably well-informed and reasonably observant and circum-

spect, taking into account social, cultural and linguistic factors in the market in question.

Claims which convey the idea that a product has a specific benefit when this benefit repre-

sents mere compliance with minimum legal requirements shall not be allowed.

The second criterion requires the truthfulness of the claims:

If it is claimed that the product contains a specific ingredient, the ingredient shall be deliber-

ately present.

Ingredient claims referring to the properties of a specific ingredient shall not imply that the

finished product has the same properties when it does not.

Marketing communications shall not imply that expressions of opinions are verified claims

unless the opinion reflects verifiable evidence.

11

Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on

cosmetic products.

12 Commission Regulation (EU) No 655/2013 of 10 July 2013 establishing common criteria for the substitu-

tion of claims for cosmetic products.


The third criterion requires evidential support for the claim, including:

Claims used must be supported by adequate and verifiable documentation.

Evidence for claim substantiation must take into account state of the art practices.

If studies are used as documentation, they shall be relevant to the product and the benefit

claimed, and they shall follow well-conducted methodologies and respect ethical considera-

tions.

Statements of clear exaggeration which are not to be taken literally by the average end user

shall not require substantiation.

A claim extrapolating (explicitly or implicitly) ingredient properties to the finished product

shall be supported by adequate and verifiable evidence.

Assessment of the acceptability of a claim shall be based on the weight of evidence of all

studies, data and information available depending on the nature of the claim and the prevail-

ing general knowledge the end users.

The fourth criterion deals with honesty:

Presentations of a product’s performance shall not go beyond the available supporting evi-

dence.

Claims shall not attribute to the product’s specific (i.e. unique) characteristics if similar prod-

ucts possess the same characteristics.

If the action of a product is linked to specific conditions, such as use in association with

other products, this shall be clearly stated.

The fifth criterion deals with the fairness of the claim, which is elaborated as:

Claims must be objective and must not constitute competitors or ingredients used legally.

No claims may be used that may give rise to confusion with a competing product.

The sixth and final criterion deals with informed decision-making, including:

Claims must be clear and understandable to the average end user.

Claims should be seen as an integral part of the product and must contain information that

allows the average end user to make an informed choice.

Marketing needs to take into account the target audience, its ability to understand the mes-

sage and that information in that regard must be clear, precise, relevant and understandable

to the target audience.

The common criteria are summarized in an indicative technical document13

that is regularly

updated and contains specific and illustrative examples of how the criteria should be under-

stood in relation to specific claims.

The assessment of whether a claim complies with applicable requirements is based on the

perception and expectations of the consumers towards the product, including those resulting

from the claim.

4.2 Claims of pro- and prebiotic cosmetic products This survey focused on how cosmetic products are marketed with "prebiotic" or "probiotic"

claims as described below. It was out of the scope of the survey to assess whether claims and

the underlying documentation for possible effects live up to good practice for claims in cosmet-

ics. As described in Chapter 2, the terms "probiotic" and "prebiotic" are neither well-defined nor

distinguished as regards cosmetic ingredients or claims of cosmetic products. Therefore, there

is no distinction between "probiotic" and "prebiotic" claims in this section.

13

“Technical document on cosmetic claims”: https://ec.europa.eu/docsroom/documents/24847

https://ec.europa.eu/docsroom/documents/24847


In the retailer survey, some cosmetics brands were identified that market the entire product's

series as pro- or prebiotic, for example, by using the label "Probiotic Skincare" as part of the

brand logo. However, there are often some products in the series that do not contain pro- or

prebiotic ingredients, e.g. pure oils.

Most brands have a single product or a few products marketed as pro- or prebiotic in a skin

care series. The claim is typically displayed on the product description printed on the packag-

ing or displayed on the retailer's product website, or is part of the product/brand name that

appears on the front of the packaging (e.g. "[brand name] Probiotic cleanser").

The claims of the identified products were analysed and divided into six groups depending on

the health-related claim (TABLE 9). The vast majority of claims relate to positive effects on the

skin and most products are claimed to have several effects.

TABLE 9. Breakdown of claims in groups by related effects.

Claim group by

effect Description Examples of claims within the group

Skin problems Claim to counteract or remedy

skin problems such as red-

ness, irritated skin, or swell-

ing.

Claim on a face cream on the packaging: "... cream with probiotic technology... Extra-gentle,

oil-free moisturizing cream suitable for skin with per-

sistence or reactive redness. Instantly comforts and

soothes. Relieves the appearance of visible redness,

soothes to cool discomfort and quells blotchiness to

restore a more even skin tone. "

Skin diseases Claim to counteract or remedy

skin disorders such as acne,

psoriasis or rosacea.

Claim on a make-up remover from a product website: " Prebiotics stimulates the formation of the good bac-

teria and helps fight the bacteria that make unclean

skin and acne " [translated from Danish]

Skin type Claim to be particularly suita-

ble for certain skin types,

such as sensitive skin, oily

skin and/or dry skin.

Claim on a body lotion from a product website: " Probiotic strengthens the cells' detoxification pro-

cess and normalizes skin pH... recommended for dry

and delicate skin, both for children and adults. " [translated from Danish]

General positi-

ve health ef-

fects

Claim to cause general posi-

tive health effects on the skin,

e.g. better skin balance, mois-

turizing, softening, strength-

ening the skin's defense

mechanisms, stimulating

and/or calming.

Claim on a face serum from a product website: "Probiotic technology helps strengthening and pro-

tecting the skin against external aggressions by pro-

moting hydration. " [translated from Danish] Claim on a face cream from a product website: "Revolutionary double-acting, multiuse enzyme polish

that transforms and lightens dull, rough, clogged and

energy-reduced skin. Comprising... probiotics and

peptide complex that balances and protects the skin,

and 100% pure bio-organic oil that emulsifies upon

contact with water." [translated from Danish]

Aging Claim to counteract skin ag-

ing, e.g. slow down the aging

process, make wrinkles and

lines less visible.

Claim on a face serum from a product website: "... Inactivated probiotic Lactobacillus cells are added

to stimulate the skin's production of ß-defensins.

These peptides change the micropopulation of the

skin in a way that favors the beneficial strains so that

they can compete with the aging strains." [translated

from Danish]


Microorganisms Claim to affect the composi-

tion of the skin's microorgan-

isms.

Claim of a bodylotion from a product website: "Prebiotic * - Helps restore the beneficial microflora in

the skin of the child " [translated from Danish] Claim of a deodorant o from a product website: "Prebiotics inhibit the bacteria that cause bad body

odor " [translated from Danish] Claim a face cream from a product website. "Prebiotics favor the growth of beneficial microbes.

Probiotics... contain an extract of probiotic Lactobacil-

lus species. The extract will increase the amount of

beneficial microbes on the skin. " [translated from

Danish]

Most of the pro-/prebiotic claims also emphasize some general positive health effects associ-

ated with the pro-/prebiotic ingredients, such as "moisturizing" or "strengthening the skin's

defense mechanisms". These claims, however, are not specific to products with pro-/prebiotic

claims, but are generally found for many cosmetic skin products.

For 17 out of the 80 products with pro-/prebiotic claims (Section 3.2.2) it is indicated that the

pro-/prebiotic ingredients have an effect on the skin's bacterial flora, usually either by promot-

ing beneficial bacteria or by inhibiting harmful bacteria (TABLE 10). Comparing the claim type

and ingredients, no clear pattern between occurrence of certain ingredients and claiming of

certain effects was identified.


TABLE 9. Number of products with claims about effects related to content of pro-/prebiotic

ingredients.

Claim group by

effect

Number of products within

the claim group

Pro-/prebiotic ingredients

(number of products)*

Skin problems 19 Alpha-Glucan Oligosaccharide (5)

Inulin (5)

Lactobacillus Ferment (4)

Lactobacillus (3)

Bifida ferment lysate (2)

Lactis Proteinum (2)

Lactic acid (2)

Hansenula Ferment (1)

Kloeckera Ferment (1)

Lactococcus Ferment (1)

Leuconostoc Ferment (1)

Pediococcus Ferment (1)

Saccharomyces Ferment (1)

[Ingredients list not available] (1)

Skin diseases 6 [Ingredients list not available] (3)


Alpha-Glucan Oligosaccharide (1)







Skin type 8 Lactobacillus Ferment (4)


Inulin (2)

Lactic Acid (2)

Sodium Hyaluronate (2)


Lactobacillus (1)

General positive

health effects 51 [Ingredients list not available] (14)

Inulin (11)



Lactic Acid (9)

Lactobacillus (9)




Lactose (4)

Lactoccus ferment lysate (3)

Lactobacillus ferment lysate (2)

Hyaluronic Acid (1)

[No pro-/prebiotic ingredient identified] (1)


Saccharomyces lysate extract (1)

Sodium Lactate (1)







Aging 12 [Ingredients list not available] (5)



Inulin (2)




Lactic Acid (1)

Lactobacillus (1)

Lactose (1)

Microorganisms 17 Alpha-Glucan Oligosaccharide (12)

Inulin (9)

Lactobacillus (6)


Lactic Acid (5)



[No pro-/prebiotic ingredient identified] (1)

* Many cosmetic products contain more than one pro-/prebiotic ingredient. The sum of the number of

products indicated in this column is therefore greater than the number given in column "Number of prod-

ucts within the claim group".


5. Conclusion

Several stakeholders recognize pro- and prebiotic cosmetics as "trendy" and the market is

considered to be growing. Therefore, an increasing number of products with pro- and prebiotic

claims are expected in the future.

In the light of results from stakeholder consultation, literature/internet search, the consumer

product database and the retailer survey, the overall conclusion is that there is no clear corre-

lation between pro-/prebiotic claims and pro-/prebiotic ingredients in cosmetics.

Ingredients

Pro- and prebiotic ingredients are used as dietary supplements, and the definitions of the con-

cepts are basically developed from their use as dietary supplements, where the term probiotic

refers to in living microorganisms.

In cosmetics, the terms are used more broadly. Ingredients that lead to pro-/prebiotic claims

are broader in cosmetic applications than for dietary supplements. The definition of "probiotic"

involves the use of living microorganisms having a beneficial effect on the host whereby the

effect can be documented. However, living microorganisms are only used to a limited extent in

cosmetic products. In cosmetics, however, a number of ingredients which are produced by

microorganisms are referred to as 'probiotic'.

The INCI names of these ingredients often refer to the genus name (e.g. "Lactobacillus") fol-

lowed by one or more of these terms: "ferment", "lysate", "filtrate", "extract" (e.g. "Lactobacillus

ferment lysate"). Microorganisms used in the preparation of probiotic ingredients may, for

example, include:

Lactobacillus (most used)

Bacillus

Bifidobacterium

Lactococcus

Streptococcus

Micrococcus.

The definition of "prebiotic" substances implies that the substances result in specific changes

in the composition and/or the activity of the host’s microbiota, that the substances cannot be

degraded by the host's own enzymes, that they have a beneficial effect on the health of the

host and that the effect can be documented. In cosmetics, however, prebiotic ingredients are

less defined, i.e. they are referred to as substances that can be exploited by beneficial bacteria

or as substances produced using microorganisms (see probiotic ingredients). Prebiotic ingre-

dients may include (INCI names in capital letters):

fructooligosaccharides

galactooligosaccharides


lactulose

HYALURONIC ACID

Sodium Hyaluronate

LACTIC ACID

ACETIC ACID

diacetyl

LACTOSE

LACTIS PROTEINUM


MILK PROTEINUM

INULIN.

Alpha-Glucan Oligosaccharide, Inulin, Lactic Acid, and Lactobacillus Ferment/Lactobacillus

are the ingredients most commonly found in products with pro-/prebiotic claims in the retailer

survey. Extracts from the consumer product database also showed that ingredients produced

using Bifidobacterium and Micrococcus are often present.

Many cosmetics manufacturers have their own laboratories for the production of pro- or prebi-

otic ingredients.

In addition, there are (bio-)chemical companies that develop pro- or prebiotic ingredients.

According to the information obtained in this survey, there are currently no Danish suppliers of

pro-/prebiotic ingredients for cosmetics. Some cosmetics manufacturers indicate that the

range of raw materials is still quite limited but growing.

A number of the above-mentioned ingredients (e.g. Sodium Hyaluronate, LACTIC ACID) are

widely used in cosmetic products and their use is by no means limited to products with pro-

/prebiotic claims. In contrast, there are also some of the ingredients identified during data and

information collection and from the consumer product database which were not found in any of

the products with pro-/prebiotic claims in the retailer survey (e.g. diacetyl, Micrococcus). Some

products with pro-/prebiotic claims in the retailer survey contain no pro-/prebiotic ingredients at

all. This means that a pro-/prebiotic claim can be used as an indication of pro-/prebiotic ingre-

dients, but that there is no clear relationship between claims and ingredients.

Product types

Both stakeholder communications and the survey of products from internet retailers show that

the products with pro-/prebiotic claims are primarily leave-on products (for example, face

cream or body lotion) and include only a few rinse-off products (for example, facial scrubs or

hand soap).

Products with pro-/prebiotic claims are mainly for facial care (69%). In addition, some body

care products (11%), soap and hygiene (11%) and a few baby care, hair care and cosmet-

ics/make-up products (3% in each category) were identified. This distribution is in accordance

with the stakeholder findings that the product should remain on the skin so that the pro-

/prebiotic ingredients can have an effect.

Market shares of products with pro-/prebiotic claims

A limited overview of the market and market shares in pro-/prebiotic cosmetics in Denmark is

available. Several stakeholders estimate that these products are still niche products and that

the market share is <1% (in turnover).

The products are not yet available in convenience stores (discount markets and supermar-

kets), but are available in department stores, specialized cosmetics retailers, or pharmacies. A

significantly larger selection is available through the internet retailers. A number of products

are marketed specifically to cosmetologists.

The data on cosmetic products containing bacterially-derived ingredients from the consumer

products database revealed a fraction of only 0.59% of products containing bacterially-derived

ingredients. The data extraction showed that Lactobacillus, Micrococcus and Bifidobacterium

are the most commonly used bacteria in the names of the bacterially-derived ingredients.

However, no products with pro-/prebiotic claims were found to contain a Micrococcus ingredi-

ent in the retailer survey. This exemplifies the fact that there are products which contain bacte-

rially-derived ingredients, but which are not marketed with pro-/prebiotic claims. In contrast,

there are also products that do not contain pro-/prebiotic ingredients, but still are marketed


with probiotic/prebiotic claims. In the survey of the products in the department store, the num-

ber of the pro-/prebiotic claimed products accounted for 1.7% of all products in the facial care

category. This is in line with the stakeholder's estimate of <1%, taking into consideration that

pro-/prebiotic products are niche products and sold to a lesser extent than other products and

that the retailer survey investigation was limited to internet retailers and a department store

where products with pro-/prebiotic claims are actually sold. As mentioned above, they are not

sold in more common convenience stores such as supermarkets.

The market share estimated from the consumer product database is smaller than the estimate

from the retailer survey. This is to be expected, since the database covers all cosmetic product

categories and all products from all retailers of cosmetic products (including convenience

stores). In the retailer survey in this study, neither any convenience stores (only a department

store) nor all product categories (only leave-on facial care) were included.

Durability, pricing and eco-labelling

Prices of products with pro- and prebiotic claims are in line with other specially developed

cosmetic products. The comparison of shelf lives show that products with and without pro- and

prebiotic claims do not differ from others. This finding is in line with information from stake-

holders that products with pro-/prebiotic claims (usually) not contain living microorganisms and

therefore no difference in durability is to be expected. About one third of the products with pro-

/prebiotic claims were labelled with the ECOcert label. In addition, some products from the

department store were labelled with the Nordic Swan ecolabel.

Claims

Claims such as "probiotic", "prebiotic" or the like are typically available from the product de-

scription and printed on the packaging or displayed on the internet retailer's product website,

or are a part of the product/brand name that appears on the front of the packaging.

Most of the claims relate to some general positive health effects in skin and/or relate to allevi-

ate skin disorders and/or conditions. Claims about effects relating to changes in the skin's

natural bacterial communities seem to differentiate pro-/prebiotic cosmetics from other cosmet-

ics.

Comparison of the various claimed health effects and ingredients has indicated no clear pat-

tern between occurrence of ingredients and claims about certain effects.


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The Danish Environmental

Protection Agency

Haraldsgade 53

DK-2100 København Ø

www.mst.dk

Survey of cosmetic products with "probiotic" or "prebiotic" claims

The study provides more knowledge about pro / prebiotic cosmetics in Denmark with

regard to ingredients, products and market overview. Pro and prebiotic ingredients

are well known as dietary supplements, and their definition is based on their use in

food / dietary supplements. The common definition of "probiotic" involves the use of

living microorganisms with a beneficial proven effect on the host. However, the study

showed that living microorganisms are used only to a limited extent in cosmetic prod-

ucts. Nonetheless a number of ingredients produced by microorganisms are referred

to as "probiotic". Branch contacts estimate that pro- and prebiotic claimed products

are still niche products and the market share is below 1%. In a retailer survey 932

products were included, of which 80 unique products were with pro- and/or prebiotic

claims. The products were mainly for facial care and were found in department

stores, which primarily led specialty and luxury cosmetics, or at pharmacies. A signif-

icantly larger selection was available through internet retailers. Products claimed as

pro- and prebiotic are similarly priced as other specialty cosmetic products, and do

not differ from other cosmetics with regard to preservation and durability. Typically,

the claim as "probiotic", "prebiotic" or the like, appears in the product description

printed on the packaging, the internet retailer's product homepage, or is part of the

product/brand name printed on the packaging, and most of them relate to general

positive health effects in the skin, e.g. to create "better balance" or "moisturizing".

Survey of cosmetic products with probiotic or prebiotic claimsThe Danish Environmental Protection Agency/ Survey of cosmetic products with "probiotic" or "prebiotic" claims 3 Contents

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